Financial Capital and Taxation Policy *

This paper suggests a relatively simple analytical framework for taxing all financial arrangements. The debt/equity distinction is determined by the contingency principle. The accruals/realisation distinction is determined separately by the volatility principle. The capital/revenue character distinction is effectively removed directly or by a character hedging regime. Hybrids, synthetics, hedging arrangements and other portfolios are tax‐assessed on an aggregate, rather than a bifurcated, basis. The framework could be applied to both classical and dividend‐imputation‐based business tax systems.